SecProbe.io

Mail Stop 3561

 April 18, 2008

Via U.S. Mail

John Fahlberg Chairman, President and Chief Executive Officer The Golf Alliance Corporation
12926 Morehead
Chapel Hill, North Carolina 27517
Re:  The Golf Alliance Corporation
  Amendment No. 3 to Registra tion Statement on Form S-1
  Filed April 9, 2008   File No. 333-147056
Dear Mr. Fahlberg:

We have reviewed your responses to the comments in our letter dated March 10,
2008 and have the following additional comments .  Please note that all page references
below correspond to the clean versio n of your filing provided by counsel.

General, page 5

1. We note your response to our prior comment 4.  The revised disclosure states that
the company expects its cash on hand to cover its anticipated expenses through
2008 when the company is in Phase III.  The disclosure in the Roll-Out Strategy section states that Phase I is expected to take approximately one year and that
Phase I has not yet started.  Revise the disc losure to clear up this discrepancy in
timing.  Also include a discussion of the company’s anticipated expenses for the
rest of 2008 and how the company’s cu rrent cash on hand will cover those
expenses. Also either delete the final sentence of this section or provide us with
your basis for believing you will have 40 clubs signed up by the end of the calendar year.

John Fahlberg
The Golf Alliance Corporation
April 18, 2008 Page 2

 Summary Financial Data, page 5

2. Revise the first paragraph of  this section to remove th e reference to three months
ended October 31, 2007 and replace it w ith six months ended January 31, 2008.
 Concept, page 16

3. We note your response to our prior co mment 8.  Discuss why the company
believes that 10 rounds of golf per member  golf course per year will allow the
company to obtain approval to play at more  clubs.  To the extent helpful, provide
a discussion of how the company arrived at a limit of 10 rounds of golf per member golf course per year to ensu re such approval would be obtained.
 Revenue Distribution and Apportionment, page 17

4. We note your response to our prior comment  9 and reissue.  Disclose the annual
dues for the twenty clubs on your list.  Th is will help investors determine if the
pricing structure of the company is su fficient cover the monthly portion of the
annual dues of the twenty  clubs on your list.

Management Discussion and Analysis, page 22

5. Revise and update this sec tion (including paragraph 5 unde r Plan of Operation) to
the extent certain actions are stated  to begin by the fi rst quarter of 2008.

Part II

Item 27.  Exhibits.

6. Please state that Exhibit 10.1 was pr eviously filed on February 26, 2008.

* * * * *

As appropriate, please amend your regist ration statement in response to these
comments.  You may wish to provide us with marked copies of the amendment to
expedite our review.  Please furnish a cove r letter with your amendment that keys your
responses to our comments and provides any requested information.  Detailed cover
letters greatly facilitate our review.  Please understand that we may have additional comments after reviewing your amendmen t and responses to our comments.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Act of 1933 and that they have  provided all information investors require

John Fahlberg
The Golf Alliance Corporation
April 18, 2008 Page 3

 for an informed investment decision.  Since the company and its management are in possession of all facts relating to a company’ s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.
 Notwithstanding our comments, in the even t the company requests acceleration of
the effective date of the pending registration statement, it should furnish a letter, at the time of such request, acknowledging that:

• should the Commission or the staff, acting pursuant to delegated authority,
declare the filing effective, it does no t foreclose the Commission from taking
any action with respect to the filing;

• the action of the Commission or the st aff, acting pursuant to delegated
authority, in declaring the filing effective, does not relieve the company from
its full responsibility for the adequacy and accuracy of the disclosure in the
filing; and

• the company may not assert staff comments and the declaration of
effectiveness as a defense in any pr oceeding initiated by the Commission or
any person under the federal securities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Di vision of Corporation Finance in connection
with our review of your filing or in response to our comments on your filing.
 We will consider a written request for acceleration of the effective date of the
registration statement as conf irmation of the fact that t hose requesting acceleration are
aware of their respective re sponsibilities under the S ecurities Act of 1933 and the
Securities Exchange Act of 1934 as they rela te to the proposed public offering of the
securities specified in the above registration statement.  We will act  on the request and,
pursuant to delegated authority, grant acceleration of the effective date.

We direct your attention to Rules 46 0 and 461 regarding requesting acceleration
of a registration statement.  Please allow ad equate time after the filing of any amendment
for further review before submitting a request for acceleration.  Please provide this request at least two business days in a dvance of the requested effective date.

John Fahlberg
The Golf Alliance Corporation
April 18, 2008
Page 4

Please contact Julie Bell at (202) 551 -3574 or me at (202) 551-3750 with any
other questions.
 Regards,      Max A. Webb  Assistant Director
cc: Gregg E. Jaclin, Esq.  Anslow & Jaclin, LLP  Fax:  (732) 577-1188